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Legal · Working draft

Privacy Policy

Version 0.1 · Effective 19 April 2026 · Subject to attorney review and POPIA Information Officer registration

Working draft pending POPIA registration.

This policy describes how we handle your personal information during Fighting Chance's early access period. Registration of an Information Officer with the Information Regulator, and publication of a PAIA manual, are both in progress. If you have any concern about how your data is handled, email support@fightingchance.co.za.

1. Who we are, for privacy purposes

The Responsible Party for personal information you provide to Fighting Chance is the individual founder, pending registration of a private company. The founder acts as the current Information Officer.

Contact: support@fightingchance.co.za, subject line “Privacy.”

2. What information we collect

2.1 Information you provide directly.

Some of this falls within special personal information under POPIA — notably, information about children and health. We process it only to the extent necessary for the service you have asked us to provide.

2.2 Information collected automatically.

2.3 Information from third parties.

Currently, none. We do not receive or enrich your data with information from any third-party data broker, credit agency, or similar source.

3. Why we collect it and what we do with it

We process your personal information for the following purposes, each mapping to a lawful basis under POPIA:

PurposeLawful basis
Providing the service. Generating AI outputs, saving your progress, producing the matter package.Performance of a contract
Security and fraud prevention.Legitimate interest
Communication. Service-related emails (password resets, account notifications).Performance of a contract
Product improvement. Understanding where users struggle or abandon.Legitimate interest
Legal compliance. POPIA, Consumer Protection Act, Tax Administration Act.Compliance with a legal obligation

We do not use your data for marketing, advertising, training publicly-available AI models, selling to third-party data brokers, or profiling you for any commercial purpose.

4. Who we share it with

4.1 Third-party processors.

Current third-party processors as of 19 April 2026:
· Anthropic PBC — provider of the Claude AI models. Your inputs are sent for the limited purpose of generating responses, under terms which prohibit training on customer data.
· [Hosting provider — to be confirmed] — compute and database infrastructure.
· [Email provider — to be confirmed] — transactional email.
When specific providers are confirmed, this list will be updated and affected users notified.

4.2 Your reviewing attorney (Stage 8 only).

When you reach the attorney sign-off stage, we share your matter package with the attorney you have chosen. You control when this happens. The attorney receives the package under their own professional obligations of confidentiality.

4.3 Required disclosure.

We may disclose your data if required by a South African court order, valid subpoena, or regulator. Where not legally prohibited, we will notify you before disclosure. We have never received such a request.

5. Where your data is stored

Our intention is that your data is stored on infrastructure inside South Africa. During early access, the specific deployment region is being verified. Where a third-party processor does not have South African infrastructure, data is transmitted outside SA only briefly to generate a response. Under POPIA s72, transborder data flows for contract performance are permitted.

6. How long we keep it

We retain your data for as long as your account is active, and for 30 days after deletion (for recovery). After 30 days, deletion is irrevocable. Certain data may be retained longer where required by law:

7. Your rights under POPIA

8. Security

9. Children's information

Where your matter involves minor children, you will provide information about them. This is special personal information under POPIA s35. We do not publish, share, or use children's information for any purpose other than producing the matter package. It is deleted with your account.

10. Changes to this policy

Material changes — affecting your rights or how we handle your data — will be notified by email at least 30 days before taking effect. You may export and close your account before the change applies.

11. How to contact us about privacy

Email support@fightingchance.co.za, subject line “Privacy.” We respond within 14 days. For formal POPIA requests (access, correction, deletion, objection), say so explicitly in the subject line.

Fighting Chance · Privacy Policy v0.1 · Last updated 19 April 2026